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Food additives in Japan: "Draft report on Discussion about the Labeling System for Food Additives" published

At the 9th discussion on the Labeling System for Food Additives held on February 27, 2020, the Consumer Affairs Agency published the "Report on Discussions about the Labeling System for Food Additives (Draft)". Regarding the labeling system for additives, the trend about "-free" and "non-use" labeling has particularly drawn attention, so here is a summary of the report (draft).

[ Points ]

  • New guidelines were established for labeling such as "-free" and "non-use"
  • The terms "artificial" and "synthetic" used in expressions such as "synthetic preservative" and "artificial sweetener" are to be deleted from the Food Labeling Standard
  • To conduct a fact-finding survey regarding additives for nutrient fortification purposes to aim at the labeling of all processed foods in principle

Regarding future direction in amendment measures

(1) How the labeling of labeling grouped by categories names, labeling of abbreviated names and classification names, and labeling of function names should be

Future direction in amendment measures

Labeling grouped by categories names, abbreviated names, classification names, and functions have been implemented for more than 30 years because the labeling space is limited. Therefore, they are familiar to consumers and easy to understand for them. On the other hand, under the current system, there are some cases where which additives are used specifically and their purposes of use are not clear. For this reason, if labeling based on the Codex standard is adopted to enable each used additive identified or be checked later, the number of characters will be greatly increased. Therefore, there is an issue caused by limited labeling space as well as a concern that the same level of comprehensibility as the current state will not be able to maintain. Also, regarding the labeling of additives by numbers, as consumers are not familiar with them and the additives which are allowed to be used are different in the Codex standard compared to the Japanese system, some can be replaced with numbers, and others cannot. In addition, regarding the joint writing of the function, there are many additives which have several effects, and the selection of the usage is left to the company that uses the additives, and also there are expressions that are unfamiliar to consumers. Based on the above, it is difficult to change the current system at present.

(2) What labeling of "-free" and "non-use" should be

Future direction in amendment measures

‘Labeling of "-free", "non-use", etc.' Article 9 of the Food Labeling Standard prohibits the use of words that contradict terms to be written on labeling or characters that mislead about contents, and the Food Labeling Standards Q&A indicates the interpretation of the article, but it does not show a comprehensive interpretation of the article's regulations. Also, the Food Labeling Standards Q&A indicating the labeling methods of "-free" for additives is ambiguous. Based on the current ambiguous Food Labeling Standards Q&A, business operators voluntarily put "-free" etc. on the labeling. This is probably one of the reasons why some consumers end up with not understanding labels such as "-free", which was found in the consumer intention survey. On the other hand, it is not appropriate to uniformly prohibit labeling such as "-free". For this reason, regarding the future labeling such as "-free", it is appropriate to formulate guidelines which can be the index to decide whether some labels fall under the prohibited labeling items of the said article or not with the aim to eliminate the labeling such as "-free" that contradicts the content of items to be written on labeling or misleads about the content, which is prohibited by the Food Labeling Standards. It is expected that the development of guidelines will enhance the revision of the existing Fair Competition Code and the formulation of a new Fair Competition Code for the industry.
‘Terms of "artificial" and "synthetic"' Regarding the regulations of labeling for food additives containing or prefixing the words "artificial" and "synthetic", such as "synthetic preservatives" and "artificial sweeteners", it is considered appropriate to delete them considering the handling of additives in the current Food Sanitation Act and in the viewpoint of preventing consumers from misleading.

(3) Labeling of food additives used for nutrient fortification purposes

Future direction in amendment measures

Food additives used for the purpose of nutrient fortification are not treated as food additives in some other countries and it is important to indicate the content of vitamins, minerals, amino acids, etc. Therefore, according to the Food Sanitation Act before the enactment of the Food Labeling Act, it was supposed to be appropriate to separately arrange the labeling of nutritional components, and labeling of them was not considered necessary except for foods that require consideration for nutrition such as modified powdered milk. On the other hand, the JAS law before the enactment of the Food Labeling Act stipulated the standards according to food groups to limit the food additives that could be used, and that food additives used even for nutritional enhancement purposes must be written on labeling. Therefore, there was a difference between the two Acts in the concept for labeling of food additives used for the purpose of nutrient fortification. The concept for the food additives labeling intended for nutrient fortification under the Food Labeling Standards based on the Food Labeling Act is based on the above-mentioned methods of handling labeling under the Food Sanitation Act and the JAS Law. As a result, there are some foods that need labeling and others don't, making it difficult for consumers to understand. Internationally, in Codex, EU, Australia, etc., substances used for nutrient fortification are not considered as food additives, but all substances used must be written on the labeling. For this reason, with the consumers' needs to know the food additives used for nutrient fortification purposes in mind, it is appropriate to review the regulations of "no labeling required", and to consider writing the food additives used for nutrient fortification on labeling of all processed foods in principle. However, in conducting such a review, I think it is appropriate to perform a fact-finding survey on the current status of labeling, consumers' intentions, and the impact on business operators, as well as to obtain final conclusions in light of the discussion on "overview of labeling" at the Consumer Commission Food Labeling Section Meeting about the priority of labeling items and the issue of possible labeling space, etc.

(4) Dissemination, enlightenment, and consumer education on labeling for food additives

Future direction in amendment measures (excerpt)

The government, consumer groups, business associations, etc. are performing promotion and enlightenment about food additives including the labeling system, but in order to implement more effectively and efficiently, we believe that it is appropriate for them to cooperate by taking advantage of their respective strengths and to take an approach appropriate to the target generation. In particular, the Consumer Affairs Agency, in cooperation with each government agency, is expected to implement, for example, initiatives through dietary education, as well as initiatives targeting not only students but also professionals such as nutrition teachers and dietitians who are teaching students.

Upcoming schedules

It will take some time to revise the additives labeling system for the "nutrient fortification purposes", of which fact-finding survey is needed, and to establish guidelines for the labeling of "-free" and "non-use". On the other hand, the removal of the terms "artificial" and "synthetic" is expected to take place in a short period of time. Those who are currently displaying them on the labels should review the minutes of the discussion once.

"Report on the Discussion about the Labeling System for Food Additives (Draft)" (Consumer Affairs Agency)

January 2020